Wash. Rev. Code » Title 48 · Chapter 48.18
Revised Code of Washington

Wash. Rev. Code § 48.18.320 (2026)

Annulment of liability policies

✓ current as of May 2026
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No insurance contract insuring against loss or damage through legal liability for the bodily injury or death by accident of any individual, or for damage to the property of any person, shall be retroactively annulled by any agreement between the insurer and insured after the occurrence of any such injury, death, or damage for which the insured may be liable, and any such annulment attempted shall be void.
[1947 c 79 s .18.32; Rem. Supp. 1947 s 45.18.32.]
Notes of Decisions
Cited in 8 cases (3 in the last 5 years), 1974–2025 · leading case: Am. Cont'l Ins. Co. v. Steen, 91 P.3d 864 (Wash. 2004).
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Am. Cont'l Ins. Co. v. Steen, 91 P.3d 864 (Wash. 2004). · cites it 42× “Those questions ask: (1) Is the early cancellation of a claims-made policy that insures against loss or damage through legal liability for the bodily injury or death by accident of any individual an attempt at a prohibited retroactive "annulment" "after the occurrence of any…”
Am. Cont'l Ins. v. Steen, 91 P.3d 864 (Wash. 2004). · cites it 40× “Those questions ask: (1) Is the early cancellation of a claims-made policy that insures against loss or damage through legal liability for the bodily injury or death by accident of any individual an attempt at a prohibited retroactive “annulment” “after the occurrence of any…”
HB Dev., LLC v. W. Pac. Mut. Ins., 86 F. Supp. 3d 1164 (E.D. Wash. 2015). · cites it 4× “Legality of Early Termination Plaintiffs also argue that coverage under HB’s policy was illegally and retroactively annulled, in violation of RCW 48.18.320, because the policy was terminated early, but after Hawley and Brown had received complaints from Crook and Boughton about…”
Granite State Ins. Co., V. Pope Resources Lp (Wash. Ct. App. 2021). · cites it 46× “320, voids any agreement between an insurer and insured attempting to retroactively cancel, rescind, void, buy back, or otherwise annul an insurance contract for liability coverage after a potentially covered injury or damage to a third party has occurred. When analyzing whether…”
Manufactured Hous. Communities v. St. Paul Mercury Ins., 660 F. Supp. 2d 1208 (W.D. Wash. 2009). “More importantly, Steen concerned a Washington statute, RCW 48.18.320, which precluded “any agreement between the insured and the insurer to retroactively annul an insurance policy after the occurrence of an event for which the insurer may be liable.”
Oregon Auto. Ins. v. Salzberg, 524 P.2d 461 (Wash. Ct. App. 1974). · cites it 3× “The interpretation urged would erase the authorities cited which recognize the validity and pur *674 pose of cooperation clauses.”
Cnty. Comm'n of Fayette Cnty., West Virginia v. Nat'l Grid NE Holdings 2 LLC (S.D.W. Va 2022). “36, § 3625 ; Wash. Rev. Code § 48.18.320 . 8 6; 20-3 at 6).”
Argonaut Ins. Co. v. Travelers Cas. & Sur. Co. (W.D. Wash. 2025). “their 17 agreement violates RCW 48.18.320 and therefore is void as a matter of law.”
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